Lead RRP scope and definitions study guide
Subpart E of 40 CFR Part 745 (residential property renovation) applies to all renovations performed for compensation in target housing and child-occupied facilities. This guide sets out what the federal rule text states in 745.80 to 745.83 and 745.88: the purpose and effective dates, the exceptions based on a written determination, an EPA recognized test kit or a paint chip sample, the emergency renovation rules, the definitions of target housing (from 745.103), child-occupied facility, renovation, minor repair and maintenance activities, firm, renovator and other terms, and how EPA recognizes test kits. Many provisions carry "unless", "except" or "where" conditions, and the dates matter. goraedu is not a training provider and does not certify renovators or firms. Your State or Tribe may run its own authorized program, so check its rules too. Every point links to the regulation and quotes its exact words.
Purpose and effective dates
Subpart E applies to all renovations done for compensation in target housing and child-occupied facilities.
“applies to all renovations performed for compensation in target housing and child-occupied facilities”
One purpose of Subpart E is that owners and occupants of target housing and child-occupied facilities get information on lead-based paint hazards before these renovations begin.
“Owners and occupants of target housing and child-occupied facilities receive information on lead-based paint hazards before these renovations begin”
The other purpose is that individuals doing regulated renovations are properly trained, renovators and firms are certified, and the work practices in 745.85 are followed.
“Individuals performing renovations regulated in accordance with § 745.82 are properly trained; renovators and firms performing these renovations are certified; and the work practices in § 745.85 are followed during these renovations.”
The Subpart E training, certification and accreditation requirements and work practice standards apply in any State or Indian Tribal area that does not have a renovation program authorized under subpart Q.
“The training, certification and accreditation requirements and work practice standards in this subpart are applicable in any State or Indian Tribal area that does not have a renovation program that is authorized under subpart Q of this part.”
Effective June 23, 2008, a training program may not provide, offer or claim to provide renovator or dust sampling technician training or refresher training for EPA certification without EPA accreditation under 745.225.
“Effective June 23, 2008, no training program may provide, offer, or claim to provide training or refresher training for EPA certification as a renovator or a dust sampling technician without accreditation from EPA under § 745.225.”
On or after April 22, 2010, a firm may not perform, offer or claim to perform renovations in target housing or child-occupied facilities without EPA certification under 745.89, unless the renovation qualifies for one of the exceptions in 745.82(a) or (c).
“On or after April 22, 2010, no firm may perform, offer, or claim to perform renovations without certification from EPA under § 745.89 in target housing or child-occupied facilities, unless the renovation qualifies for one of the exceptions identified in § 745.82(a) or (c).”
On or after April 22, 2010, renovations in target housing or child-occupied facilities must be directed by renovators certified under 745.90(a) and performed by certified renovators or individuals trained under 745.90(b)(2), unless an exception in 745.82(a) or (c) applies.
“On or after April 22, 2010, all renovations must be directed by renovators certified in accordance with § 745.90(a) and performed by certified renovators or individuals trained in accordance with § 745.90(b)(2) in target housing or child-occupied facilities, unless the renovation qualifies for one of the exceptions identified in § 745.82(a) or (c).”
On or after July 6, 2010, renovations in target housing or child-occupied facilities must follow the 745.85 work practice standards and the recordkeeping in 745.86(b)(1) and (b)(6), unless the renovation qualifies for the exception in 745.82(a).
“On or after July 6, 2010, all renovations must be performed in accordance with the work practice standards in § 745.85 and the associated recordkeeping requirements in § 745.86(b)(1) and (b)(6) in target housing or child-occupied facilities, unless the renovation qualifies for the exception identified in § 745.82(a).”
Not covered here
The pamphlet date in 745.81(b), the dates from which training programs and firms could first apply (745.81(a)(1) and (a)(2)(i)), the effective date of the suspension and revocation provisions (745.81(a)(5)) and the Pre-Renovation Education Rule history in 745.81(c) are not covered point by point. We only write what an official source states, so study these parts with your certifying program's materials.
Exceptions: determinations, test kits and paint chips
Subpart E applies to all renovations done for compensation in target housing and child-occupied facilities, except for the cases listed in 745.82(a).
“This subpart applies to all renovations performed for compensation in target housing and child-occupied facilities, except for the following:”
One exception: an inspector or risk assessor (certified under 745.226 or a State or Tribal certification program authorized under 745.324) has made a written determination that the components affected are free of paint or other surface coatings with lead equal to or in excess of 1.0 mg/cm2 or 0.5% by weight, and the firm has obtained a copy.
“Renovations in target housing or child-occupied facilities in which a written determination has been made by an inspector or risk assessor (certified pursuant to either Federal regulations at § 745.226 or a State or Tribal certification program authorized pursuant to § 745.324) that the components affected by the renovation are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams/per square centimeter (mg/cm2) or 0.5% by weight, where the firm performing the renovation has obtained a copy of the determination.”
Another exception: a certified renovator, using an EPA recognized test kit and following the kit manufacturer's instructions, has tested each component affected and determined the components are free of paint or other surface coatings with lead equal to or in excess of 1.0 mg/cm2 or 0.5% by weight.
“Renovations in target housing or child-occupied facilities in which a certified renovator, using an EPA recognized test kit as defined in § 745.83 and following the kit manufacturer's instructions, has tested each component affected by the renovation and determined that the components are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 mg/cm2 or 0.5% by weight.”
A third exception: a certified renovator has collected a paint chip sample from each painted component affected, and a laboratory recognized by EPA under section 405(b) of TSCA has determined the samples are free of paint or other surface coatings with lead equal to or in excess of 1.0 mg/cm2 or 0.5% by weight.
“Renovations in target housing or child-occupied facilities in which a certified renovator has collected a paint chip sample from each painted component affected by the renovation and a laboratory recognized by EPA pursuant to section 405(b) of TSCA as being capable of performing analyses for lead compounds in paint chip samples has determined that the samples are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 mg/cm2 or 0.5% by weight.”
For both the test kit and the paint chip exceptions, if components make up an integrated whole (such as the stair treads and risers of one staircase), the renovator must test only one of them, unless they appear to have been repainted or refinished separately.
“If the components make up an integrated whole, such as the individual stair treads and risers of a single staircase, the renovator is required to test only one of the individual components, unless the individual components appear to have been repainted or refinished separately.”
Emergency renovations
Emergency renovations are renovation activities that were not planned but result from a sudden, unexpected event that, if not immediately attended to, presents a safety or public health hazard, or threatens equipment and/or property with significant damage.
“emergency renovations, which are renovation activities that were not planned but result from a sudden, unexpected event (such as non-routine failures of equipment) that, if not immediately attended to, presents a safety or public health hazard, or threatens equipment and/or property with significant damage.”
The information distribution requirements in 745.84 do not apply to emergency renovations.
“The information distribution requirements in § 745.84 do not apply to emergency renovations”
Interim controls done in response to an elevated blood lead level in a resident child are also emergency renovations.
“Interim controls performed in response to an elevated blood lead level in a resident child are also emergency renovations.”
Emergency renovations other than interim controls are also exempt from the warning sign, containment, waste handling, training and certification requirements in 745.85, 745.89 and 745.90, only to the extent necessary to respond to the emergency.
“Emergency renovations other than interim controls are also exempt from the warning sign, containment, waste handling, training, and certification requirements in §§ 745.85, 745.89, and 745.90 to the extent necessary to respond to the emergency.”
Emergency renovations are not exempt from the cleaning requirements of 745.85(a)(5), which must be done by certified renovators or individuals trained under 745.90(b)(2).
“Emergency renovations are not exempt from the cleaning requirements of § 745.85(a)(5), which must be performed by certified renovators or individuals trained in accordance with § 745.90(b)(2)”
Emergency renovations are also not exempt from the cleaning verification requirements of 745.85(b), which must be done by certified renovators, or from the recordkeeping requirements of 745.86(b)(6) and (b)(7).
“the cleaning verification requirements of § 745.85(b), which must be performed by certified renovators, and the recordkeeping requirements of § 745.86(b)(6) and (b)(7).”
Target housing and child-occupied facilities
Target housing is any housing built before 1978, except housing for the elderly or persons with disabilities or any 0-bedroom dwelling, unless any child less than 6 years of age lives or is expected to live in such housing.
“Target housing means any housing constructed prior to 1978, except housing for the elderly or persons with disabilities or any 0-bedroom dwelling (unless any child who is less than 6 years of age resides or is expected to reside in such housing).”
A child-occupied facility is a building, or portion of a building, constructed prior to 1978, visited regularly by the same child under 6 years of age on at least two different days within any week (Sunday through Saturday), where each day's visit lasts at least 3 hours, the combined weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours.
“Child-occupied facility means a building, or portion of a building, constructed prior to 1978, visited regularly by the same child, under 6 years of age, on at least two different days within any week (Sunday through Saturday period), provided that each day's visit lasts at least 3 hours and the combined weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours.”
Child-occupied facilities may include, but are not limited to, day care centers, preschools and kindergarten classrooms.
“Child-occupied facilities may include, but are not limited to, day care centers, preschools and kindergarten classrooms.”
Child-occupied facilities may be located in target housing or in public or commercial buildings.
“Child-occupied facilities may be located in target housing or in public or commercial buildings.”
In public or commercial buildings that contain child-occupied facilities, the child-occupied facility takes in only the common areas routinely used by children under age 6, such as restrooms and cafeterias.
“areas in public or commercial buildings that contain child-occupied facilities, the child-occupied facility encompasses only those common areas that are routinely used by children under age 6, such as restrooms and cafeterias.”
Common areas that children under age 6 only pass through, such as hallways, stairways and garages, are not included.
“Common areas that children under age 6 only pass through, such as hallways, stairways, and garages are not included.”
On the exterior of public or commercial buildings that contain child-occupied facilities, the child-occupied facility takes in only the exterior sides immediately adjacent to the child-occupied facility or to the common areas routinely used by children under age 6.
“with respect to exteriors of public or commercial buildings that contain child-occupied facilities, the child-occupied facility encompasses only the exterior sides of the building that are immediately adjacent to the child-occupied facility or the common areas routinely used by children under age 6.”
Not covered here
745.83 says the definitions in 745.103 also apply to Part 745; the target housing point above quotes 745.103 (Subpart F). The 745.103 definitions of housing for the elderly and 0-bedroom dwelling are not set out point by point. We only write what an official source states, so study these parts with your certifying program's materials.
Renovation and minor repair and maintenance
Renovation means modifying any existing structure, or portion of it, in a way that disturbs painted surfaces, unless the activity is performed as part of an abatement as defined in 745.223.
“Renovation means the modification of any existing structure, or portion thereof, that results in the disturbance of painted surfaces, unless that activity is performed as part of an abatement as defined by this part (40 CFR 745.223).”
Renovation includes (but is not limited to) the removal, modification or repair of painted surfaces or painted components, such as modifying painted doors, surface restoration, window repair and surface preparation such as sanding or scraping.
“The term renovation includes (but is not limited to): The removal, modification or repair of painted surfaces or painted components (e.g., modification of painted doors, surface restoration, window repair, surface preparation activity (such as sanding, scraping, or other such activities that may generate paint dust))”
Renovation also includes removing building components, weatherization projects (such as cutting holes in painted surfaces for blown-in insulation or attic access, or planing thresholds for weather-stripping), and interim controls that disturb painted surfaces.
“the removal of building components (e.g., walls, ceilings, plumbing, windows); weatherization projects (e.g., cutting holes in painted surfaces to install blown-in insulation or to gain access to attics, planing thresholds to install weather-stripping), and interim controls that disturb painted surfaces.”
A renovation done to convert a building, or part of one, into target housing or a child-occupied facility is a renovation under Subpart E.
“A renovation performed for the purpose of converting a building, or part of a building, into target housing or a child-occupied facility is a renovation under this subpart.”
Renovation does not include minor repair and maintenance activities.
“The term renovation does not include minor repair and maintenance activities.”
Minor repair and maintenance activities are activities, including minor heating, ventilation or air conditioning work, electrical work and plumbing, that disrupt 6 square feet or less of painted surface per room for interior activities or 20 square feet or less of painted surface for exterior activities. The conditions in the next point must also be met.
“Minor repair and maintenance activities are activities, including minor heating, ventilation or air conditioning work, electrical work, and plumbing, that disrupt 6 square feet or less of painted surface per room for interior activities or 20 square feet or less of painted surface for exterior activities”
Work counts as minor repair and maintenance only where none of the work practices prohibited or restricted by 745.85(a)(3) are used and the work does not involve window replacement or demolition of painted surface areas.
“where none of the work practices prohibited or restricted by § 745.85(a)(3) are used and where the work does not involve window replacement or demolition of painted surface areas.”
When painted components, or portions of them, are removed, the entire surface area removed is the amount of painted surface disturbed.
“When removing painted components, or portions of painted components, the entire surface area removed is the amount of painted surface disturbed.”
Jobs, other than emergency renovations, done in the same room within the same 30 days must be treated as the same job when deciding whether the work is a minor repair and maintenance activity.
“Jobs, other than emergency renovations, performed in the same room within the same 30 days must be considered the same job for the purpose of determining whether the job is a minor repair and maintenance activity.”
Not covered here
The 745.83 definitions of "component" (with its lists of interior and exterior components) and "painted surface" are not set out point by point. We only write what an official source states, so study these parts with your certifying program's materials.
Firms, renovators and other terms
A firm is a company, partnership, corporation, sole proprietorship or individual doing business, association or other business entity; a Federal, State, Tribal or local government agency; or a nonprofit organization.
“Firm means a company, partnership, corporation, sole proprietorship or individual doing business, association, or other business entity; a Federal, State, Tribal, or local government agency; or a nonprofit organization.”
A renovator is an individual who either performs renovations or directs workers who perform them.
“Renovator means an individual who either performs or directs workers who perform renovations.”
A certified renovator is a renovator who has successfully completed a renovator course accredited by EPA or an EPA-authorized State or Tribal program.
“A certified renovator is a renovator who has successfully completed a renovator course accredited by EPA or an EPA-authorized State or Tribal program.”
Interim controls are measures designed to temporarily reduce human exposure or likely exposure to lead-based paint hazards, including specialized cleaning, repairs, maintenance, painting, temporary containment, ongoing monitoring, and management and resident education programs.
“Interim controls means a set of measures designed to temporarily reduce human exposure or likely exposure to lead-based paint hazards, including specialized cleaning, repairs, maintenance, painting, temporary containment, ongoing monitoring of lead-based paint hazards or potential hazards, and the establishment and operation of management and resident education programs.”
The pamphlet is the EPA pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools, or any State or Tribal pamphlet approved by EPA under 40 CFR 745.326 that is developed for the same purpose.
“Pamphlet means the EPA pamphlet titled Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools developed under section 406(a) of TSCA for use in complying with section 406(b) of TSCA, or any State or Tribal pamphlet approved by EPA pursuant to 40 CFR 745.326 that is developed for the same purpose.”
Reproductions of the pamphlet count when copied in full and without revision or deletion of material, except for adding or revising State or local sources of information.
“This includes reproductions of the pamphlet when copied in full and without revision or deletion of material from the pamphlet (except for the addition or revision of State or local sources of information).”
Cleaning and containment terms
The work area is the area that the certified renovator establishes to contain the dust and debris generated by a renovation.
“Work area means the area that the certified renovator establishes to contain the dust and debris generated by a renovation.”
Vertical containment is a vertical barrier of plastic sheeting or other impermeable material over scaffolding or a rigid frame, or an equivalent system of containing the work area. It is required for some exterior renovations but may be used on any renovation.
“Vertical containment means a vertical barrier consisting of plastic sheeting or other impermeable material over scaffolding or a rigid frame, or an equivalent system of containing the work area. Vertical containment is required for some exterior renovations but it may be used on any renovation.”
A HEPA vacuum has a high-efficiency particulate air (HEPA) filter as the last filtration stage; a HEPA filter is capable of capturing particulates of 0.3 microns with 99.97% efficiency.
“HEPA vacuum means a vacuum cleaner which has been designed with a high-efficiency particulate air (HEPA) filter as the last filtration stage. A HEPA filter is a filter that is capable of capturing particulates of 0.3 microns with 99.97% efficiency.”
A HEPA vacuum must be designed so that all the air drawn in is expelled through the HEPA filter with none leaking past it, and it must be operated and maintained according to the manufacturer's instructions.
“The vacuum cleaner must be designed so that all the air drawn into the machine is expelled through the HEPA filter with none of the air leaking past it. HEPA vacuums must be operated and maintained in accordance with the manufacturer's instructions.”
A cleaning verification card is a card developed and distributed, or otherwise approved, by EPA for deciding, by comparing wet and dry disposable cleaning cloths with the card, whether post-renovation cleaning has been properly completed.
“Cleaning verification card means a card developed and distributed, or otherwise approved, by EPA for the purpose of determining, through comparison of wet and dry disposable cleaning cloths with the card, whether post-renovation cleaning has been properly completed.”
A dry disposable cleaning cloth is a commercially available dry, electrostatically charged, white disposable cloth designed for cleaning hard surfaces such as uncarpeted floors or counter tops.
“Dry disposable cleaning cloth means a commercially available dry, electrostatically charged, white disposable cloth designed to be used for cleaning hard surfaces such as uncarpeted floors or counter tops.”
Not covered here
The 745.83 definitions of wet disposable cleaning cloth and wet mopping system are not set out point by point. How the cleaning verification card and cloths are used during post-renovation cleaning verification is set out in 745.85(b), not here. We only write what an official source states, so study these parts with your certifying program's materials.
Recognized test kits
A recognized test kit is a commercially available kit recognized by EPA under 745.88 as capable of letting a user determine the presence of lead at levels equal to or in excess of 1.0 mg per square centimeter, or more than 0.5% lead by weight, in a paint chip, paint powder or painted surface.
“Recognized test kit means a commercially available kit recognized by EPA under § 745.88 as being capable of allowing a user to determine the presence of lead at levels equal to or in excess of 1.0 milligrams per square centimeter, or more than 0.5% lead by weight, in a paint chip, paint powder, or painted surface.”
Effective June 23, 2008, EPA recognizes the test kits that National Institute of Standards and Technology research found to meet the negative response criteria in 745.88(c)(1).
“Effective June 23, 2008, EPA recognizes the test kits that have been determined by National Institute of Standards and Technology research to meet the negative response criteria described in paragraph (c)(1) of this section.”
No other test kits will be recognized until they are tested through EPA's Environmental Technology Verification Program or another equivalent EPA approved testing program.
“No other test kits will be recognized until they are tested through EPA's Environmental Technology Verification Program or other equivalent EPA approved testing program.”
Effective September 1, 2008, to start the testing process a test kit manufacturer must submit a sufficient number of kits, with the instructions for using them, to EPA.
“Effective September 1, 2008, to initiate the testing process, a test kit manufacturer must submit a sufficient number of kits, along with the instructions for using the kits, to EPA.”
After September 1, 2010, test kits must meet both of the response criteria in 745.88(c).
“After September 1, 2010, test kits must meet both of the criteria in paragraph (c) of this section.”
Negative response criterion: for paint containing lead at or above the regulated level (1.0 mg/cm2 or 0.5% by weight), a demonstrated probability (with 95% confidence) of a negative response less than or equal to 5% of the time.
“For paint containing lead at or above the regulated level, 1.0 mg/cm2 or 0.5% by weight, a demonstrated probability (with 95% confidence) of a negative response less than or equal to 5% of the time.”
Positive response criterion: for paint containing lead below the regulated level (1.0 mg/cm2 or 0.5% by weight), a demonstrated probability (with 95% confidence) of a positive response less than or equal to 10% of the time.
“For paint containing lead below the regulated level, 1.0 mg/cm2 or 0.5% by weight, a demonstrated probability (with 95% confidence) of a positive response less than or equal to 10% of the time.”
Not covered here
How long the recognition under 745.88(a) lasts, the interim rule for kits before September 1, 2010 in 745.88(b)(3), and EPA's review of test reports and notices to kit manufacturers in 745.88(b)(2) and (b)(5)-(6) are not covered point by point. The list of kits EPA currently recognizes is not given here. We only write what an official source states, so study these parts with your certifying program's materials.
Sources
- eCFR: 40 CFR 745.80, Purpose (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.81, Effective dates (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.82, Applicability (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.103, Definitions (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.83, Definitions (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.88, Recognized test kits (as of Nov 4, 2026)Checked November 6, 2026
Other EPA Lead RRP study guides: Firm and renovator certification and training, Pre-renovation information and recordkeeping, Work practice standards, Cleaning verification and dust clearance, Lead hazard standards and abatement basics